Anti-Slavery Policy

Policy Statement

Monay Pay, Inc. ("Monay," "we," "us," or "our") is committed to preventing slavery and human trafficking in our corporate activities and our supply chains. This policy applies to all persons working for us or on our behalf, including employees, contractors, consultants, and suppliers.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labor, and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

Our Organization

Monay is a financial technology company providing payments and wallet services for personal users and businesses. We operate primarily in the United States and work with a network of financial services partners to deliver our products.

Given the nature of our business as a technology and financial services company, we consider our risk of direct involvement in modern slavery to be low. However, we remain vigilant and committed to ensuring ethical practices throughout our operations and supply chain.

Our Supply Chains

Our supply chains primarily include:

• Technology and software service providers
• Cloud infrastructure and hosting providers
• Financial services and banking partners
• Identity verification and compliance service providers
• Professional services firms (legal, accounting, consulting)
• Office supplies and equipment vendors

Our Policies

We operate internal policies to ensure we are conducting business ethically. These include:

• Code of Conduct: Our code makes clear to employees the actions and behavior expected of them. We strive to maintain the highest standards of employee conduct.
• Supplier Due Diligence: We conduct due diligence on new suppliers before they are onboarded and expect our suppliers to comply with applicable laws and ethical standards.
• Whistleblowing Policy: We encourage all employees, suppliers, and partners to report concerns about any aspect of our business, including any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

Employee and Contractor Expectations

All persons working for us or on our behalf must:

• Comply with all applicable laws, including laws prohibiting slavery and human trafficking
• Conduct business ethically and with integrity
• Report any concerns or suspicions of modern slavery in any part of our business or supply chains
• Not engage in, facilitate, or support the use of forced, compulsory, or trafficked labor

Supplier Expectations

We expect all suppliers and business partners to:

• Comply with all applicable anti-slavery and human trafficking laws
• Maintain their own policies and procedures to prevent modern slavery
• Allow reasonable auditing of their compliance practices upon request
• Promptly report any concerns or violations

We may terminate relationships with suppliers who fail to meet these expectations.

Reporting Concerns

We encourage anyone who suspects or witnesses modern slavery or human trafficking in connection with our business to report their concerns. You may report concerns to:

• Your manager or supervisor (for employees)
• Our compliance team at compliance@monay.com
• Our anonymous reporting channel

We will not retaliate against anyone who reports a concern in good faith. All reports will be investigated appropriately.

Review and Oversight

This policy is reviewed annually by Monay leadership to assess its effectiveness and make improvements as needed. We are committed to continuous improvement in our approach to identifying and addressing modern slavery risks.

Contact Us

If you have questions about this policy, please contact us at: